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Keywords

plaintiffstatuteinjunctiondiscriminationclass actionliens

jurisdictioninjunctionclass actionliens

Related Cases

Korab v. Fink

Facts

The case involved a class action suit brought by non-immigrant aliens residing in Hawai'i under COFA, who alleged that Hawai'i's new health plan provided them with less health coverage than what was available to citizens and qualified aliens eligible for federal Medicaid reimbursements. After Congress's 1996 Welfare Reform Act rendered certain aliens ineligible for federal benefits, Hawai'i initially included COFA Residents in its health insurance plans but later created a new plan with limited coverage due to budget constraints. The plaintiffs argued that this change constituted discrimination based on alienage.

In this class action suit on behalf of adult, non-pregnant COFA Residents, Tony Korab, Tojio Clanton, and Keben Enoch (collectively 'Korab') claim that Basic Health Hawai'i violates the Equal Protection Clause of the Fourteenth Amendment because it provides less health coverage to COFA Residents than the health coverage that Hawai'i provides to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid.

Issue

Did Hawai'i's new health plan for COFA Residents violate the Equal Protection Clause by providing them with less health coverage than that provided to citizens and qualified aliens?

Rule

The court applied rational-basis review to Hawai'i's decision not to provide the same level of health benefits to COFA Residents as it did to citizens and qualified aliens, determining that states have discretion in setting eligibility for state benefits for certain categories of aliens.

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. See 8 U.S.C. 1601 et seq.

Analysis

The court reasoned that while the Equal Protection Clause generally requires states to treat lawfully present aliens the same as citizens, the federal statutes governing alien classifications are subject to rational-basis review. The court found that Hawai'i's decision to limit benefits for COFA Residents was permissible under the federal law, which allows states to determine eligibility for state benefits for certain categories of aliens. The court concluded that Hawai'i was not constitutionally obligated to provide the same level of benefits as it did for citizens and qualified aliens.

The Equal Protection Clause of the Fourteenth Amendment provides that '[n]o State shall . . . deny to any person within its jurisdiction the equal protection of the laws.' U.S. Const. amend. XIV, 1. Accordingly, states must generally treat lawfully present aliens the same as citizens, and state classifications based on alienage are subject to strict scrutiny review. See In re Griffiths , 413 U.S. 717, 719-22, 93 S. Ct. 2851, 37 L. Ed. 2d 910 (1973).

Conclusion

The Ninth Circuit vacated the district court's preliminary injunction, ruling that Hawai'i's decision to reduce state-paid health benefits for COFA Residents was not unconstitutional and was subject to rational-basis review.

The preliminary injunction vacated. Case remanded.

Who won?

Hawai'i prevailed in the case because the court found that it was not required to fill the funding gap left by Congress and that its decision was permissible under the law.

Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents.

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